I, James McLaren, hereby declare as follows:

I. PROFESSIONAL EXPERIENCE

1. My date of birth is [______________], and I reside at [_______________].

2. I graduated from the University of Waterloo with a Bachelor of Science in Chemistry (with honors) in 1969. I then obtained a Master of Science in Civil Engineering, also from the University of Waterloo, in 1972. I have been a Professional Engineer licensed in British Columbia for more than thirty (30) years.

3. For nearly twenty (20) years, I worked as a government pollution regulator in Canada. From 1972 through 1975, I worked as the Supervisor of Pollution Control for the Department of Indian and Northern Affairs in Yellowknife, Northwest Territories. After that, I worked for approximately seventeen (17) years in different roles at the British Columbia Ministry of the Environment (the “Ministry”), for the Kootenay Region. This region is home to the Celgar Mill, located in Castlegar (the “Celgar Mill” or “Mill”). From 1975 until 1981, I served in the Ministry as the Assistant Regional Manager of Pollution Control, which later became known as “Waste Management.” In this capacity, I supervised engineers, biologists, and other technicians who monitored any qualifying entity that discharged waste product into rivers, air or lands. Essentially, we supervised all entities that required a pollution control permit for their operations. One of my principal responsibilities was to assist in the prosecution of entities that violated the emissions conditions established in their respective pollution control permits. I am not an attorney; I was responsible for the technical elements of prosecutions, which were coordinated by an attorney for the British Columbia government.